Actions on Decisions (AOD)
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An Action on Decision (AOD) is a formal memorandum prepared by the IRS Office of Chief Counsel that announces the future litigation position the IRS will take with regard to the court decision addressed by the AOD.

The following list presents these documents in reverse chronological order, starting in the calendar year 1997.

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2000-02 Ahadpour v. Comm., T.C. Memo. 1999-9. This Action on Decision reflects the Service's acquiescence in the Court's conclusion, to the extent, that the Tax Court held that petitioners had only a conditional right to retain the escrow pa 03/03/2000
2011-04 Appleton v. Comm., No. 10-4522 (3d Cir. June 10, 2011) Whether the 3rd Circuit erred in holding that the government of the U.S. Virgin Islands should be permitted to intervene in the Tax Court deficiency proceeding pursuant to Fed. R. Civ. P. 24(b)(2). 11/08/2011
2001-02 Arnold W. Vinick v. USA, 205 F.3d 1 (1st Cir. 2000). Reflects the Service's nonacquiescence in the First Circuit's reversal of the lower court's decision that Vinick was liable as a responsible person under section 6672 for the unpaid withholding t 02/27/2001
2012-01 Baer Revoc.Trust v. U.S.,105 AFTR 2d 1544, 2 (D. Neb. 2010) Whether the stock includible in Decedent’s gross estate qualifies for the marital deduction under Sec. 2056(b)(7) when the stock is subject to contingent bequests. 04/09/2012
1998-01 Beatty v. Commissioner, 106 T.C. 268 (1996). Reflects the Service's agreement that a county sheriff was entitled to reduce his gross receipts by costs of goods sold in computing income from providing meals to prisoners. 03/03/2000
2002-05 Beck v. Comm., T.C. Memo 2001-198 (July 30, 2001). This Action on Decision reflects the Service's acquiescence, and that the action on decision dated December 17, 2001, is withdrawn, in the court's conclusion that it had the authority to review respon 12/09/2002
1998-02 Bilzerian v. United States, 86 F.3d 1067 (11th Cir. 1996) Reflects the Service's acquiescence in the result reached by the Eleventh Circuit in holding that once an assessed tax liability is paid by the taxpayer, the Service cannot use administrative c 03/03/2000
1999-10 Boyd Gaming Corporation v. Comm., 9th Cir. 1999. Reflects the Service's acquiescence in the Court's conclusion that held that the taxpayer's particular security and other business-related concerns provided sufficient justification for its polic 03/03/2000
1997-03 Buckeye Countrymark v. Comm., 103 T.C. 547 (1994) Reflects the Service's agreement that nonexempt cooperatives subject to subchapter T of the Internal Revenue Code are permitted to carry back losses from furnishing goods and services to its mem 03/03/2000
2017-01 Burnett Ranches, Ltd v. United States, 753 F.3d 143 (5th Cir. 2014), aff’g 113 A.F.T.R.2d (RIA) 2014-2178 (N.D. Tex. 2012) Nonacquiescence to the holding that a limited partnership was not a farming syndicate because the sole shareholder of a limited partner S Corporation actively participated in the farming business. 02/13/2017
2017-07 Carol A. and Roy E. Stanley v. United States W.D. Ark. No:5:14-cv-5236 (2015) Nonacquiescence to holdings that mere possession of stock certificate constitutes ownership, and work performed in a rental real estate activity may constitute work in other activities under § 469. 10/31/2017
1998-07 Clark D. & Janis L. Pulliam v. Comm., T.C. Memo. 1997-274. This Action on Decision reflects the Service's disagreement with the Tax Court's opinion, on the facts presented, that protecting against competition and retaining a key employee are valid corporat 03/03/2000
1999-16 Conway v. Commissioner, 111 T.C. 350 (1998) Reflects the Service's acquiescence in the Court's conclusion that held that the transaction was a nontaxable exchange pursuant to section 1035. Consequently, the 10-percent penalty under section 03/03/2000
2016-01 Cosentino v. Commissioner, T.C. Memo. 2014-186 Nonacquiescence relating to the holding that an amount the taxpayers received, to settle a claim that they incurred additional income tax liability because of the tax professional's advice that they e 04/01/2016
2009-01 Cox v. Comm., 514 F.3d 1119 (10th Cir. 2008), rev'g 126 T.C. 367 Whether indirect consideration of a tax liability in conjunction with evaluating collection alternatives disqualifies an appeals officer from conducting a subsequent CDP hearing focusing on that liabi 05/07/2009
2002-06 Curell v. U.S., 2001-2 U.S.T.C. Para. 50,740 (S.D. Ohio 2001). This Action on Decision reflects the Service's nonacquiescence as to whether an LL.M. in Taxation qualify as a “special factor” justifying an award of attorneys’ fees to plaintiff’s counsel in excess 12/09/2002
2012-03 Decision: L & S Industrial & Marine, Inc. v. United States, 633 F.Supp.2d 727 (D. Minn. 2009) Whether L & S Industrial & Marine, Inc.’s (Taxpayer) vessels engaged in “commercial waterway transportation” as defined in § 4042(d)(1) of the Internal Revenue Code (Code). 09/12/2012
2000-06 Diane Fernandez v. Commissioner, 114 T. C. No 21. Reflects the Service's acquiescence in the court's conclusion holding that when a taxpayer makes a requisite election under sections 6015(b) and/or (c) along with its request under section 6015(f), 09/25/2000
2004-05 Diane Fernandez v. Comm., 114 T. C. 324 (2000) Docket No. 16710-99. This Action of Decision reflects the Service's acquiescence in results only as to whether the Tax Court has jurisdiction, under I. R. C. Sec. 6015(e) in a case involving an under 08/30/2004
2014-01 Dixon v. Commissioner, 141 T.C. No. 3 (2013) Nonacquiescence relating to whether the Service is obligated to honor an employer’s designation of delinquent employment tax payments toward a specific employee’s income tax liability. 01/01/1900
2003-01 Doyle, Dane, Bernbach, Inc. v. Comm., 79 T.C. 101 (1982). This Action on Decision reflects the Service's acquiescence, and that the action on decision approved on June 27, 1988, is withdrawn, that a New York State corporate franchise tax refund attributable 01/03/2003
1999-13 Dubin v. Commissioner, 99 T.C. 325 (1992) . Reflects the Service's acquiescence in the court's conclusion that held although section 6231(a)(12) expressly provides that a husband and wife who have a joint interest in a partnership shall be 03/03/2000
1999-17 Duke Energy Natural Gas Corporation v. Comm. Reflects the Service's nonacquiescence in the court's conclusion holding that natural gas gathering systems are property includible in asset class 13.2 and must be depreciated over a 7-year period. 03/03/2000
1997-04 Duncan v. U.S., Docket No. 95-228 (U.S. D.C.,E.D. Ky.) Reflects the Service's agreement that disability benefits paid from a Kentucky policemen and firefighter's retirement fund can be excluded from gross income under I.R.C. § 104(a)(1) as benefits 03/03/2000
1999-01 Eisenberg v. Comm., 155 F. 3d 50 (2d Cir. 1998). This Action on Decision reflects the Service's acquiescence in the Court's conclusion, to the extent, that it held that there is no legal prohibition against the discount in the value of a gift of 03/03/2000
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